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3.17 UNAVOIDABLE ADVERSE ENVIRONMENTAL 

IMPACTS/CEQA CONCLUSIONS

This program EIS/EIR represents the first conceptual planning stage of a tiered 

environmental evaluation that analyzes a broad range of potential railway 

improvements and expanded passenger service. Implementation of proposed 

improvements would require further site-specific environmental analysis once

detailed project descriptions and work plans are composed. At the conclusion of 

the environmental review process, SLOCOG, FRA, other agencies, and the railroad 

owner (Union Pacific Railroad) are expected to continue discussions and 

negotiations towards an agreement regarding what, if any, physical improvements 

are necessary to allow for the proposed expansion of passenger rail service. 

Each technical chapter in this document identifies potential environmental impacts 

that could occur should one or more elements of the Build Alternative be 

constructed. The Summary describes these general findings. The Build Alternative 

looks at the entire program of proposed physical and rail service improvements. In 

many cases, one or more individual improvements are the ‘trigger’ for potential

environmental impacts, with other improvements having lesser capacity for 

potentially adverse/significant effects. Careful design of physical improvements can 

potentially avoid/minimize the vast majority of the effects discussed in this 

document. Many potentially adverse/significant impacts described in this 

document can be avoided or minimized by selecting an alignment option that avoids 

or minimizes impacts on environmental resources through refinement to the design 

or specific location of various track improvements or station areas or through 

incorporation of mitigation measures. 

Overall, expanded passenger rail service may decrease regional emissions of air 

pollutants and greenhouse gases, while decreasing transportation-related energy 

use. However, construction of proposed physical improvements would result in 

temporary, localized emissions and one-time energy consumption. 

New passenger service stations in King City and Soledad may affect circulation on 

local roadways that may increase congestion, as further discussed below. 

Additionally, much of the Monterey County within the study area is Prime and 

protected farmland, as designated by the state. Other land uses include habitat for 

special-status species, protected forest, or wetlands. New alignment options may 
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traverse such land use types and alter the designated use. Lastly, several of the 

alignment options and proposed improvements may potentially displace residences 

or businesses. 

Whether any of these potential effects will occur depends on the type, number, and 

timing of proposed physical or service improvements. As these improvements move 

forward for further design or other refinements, the extent to which any of them 

could result in substantial and/or adverse environmental effects will be analyzed 

through pertinent requirements of CEQA and/or NEPA. 

CEQA and NEPA Significance

Use of the term “significant” differs between NEPA and CEQA. According to the 

Council on Environmental Quality (CEQ)1, the NEPA determination of significance is 

based on context and intensity. Thus the magnitude of the impact is evaluated and 

described in the environmental document. The EIS reports all impacts and discusses 

feasible mitigation. Under CEQA, identification on each significant effect on the 

environment is required, according to the CEQA Guidelines § 15126.2. The 

discussion should include relevant specifics of the affected area, resources involved, 

physical changes, significant environmental effects the project might bring, and 

feasible mitigation. 

According to the CEQ, the manner in which the differences between the two 

processes are addressed must account that NEPA does not compel mandatory 

findings of significance, and that some impacts determined to be significant under 

CEQA may not be necessarily be determined significant under NEPA. As such, 

mitigation strategies outlined in this program-level EIS/EIR may be appropriate 

under NEPA, but the potential impacts they address may not be considered under 

CEQA.

3.17.1 UNAVOIDABLE POTENTIALLY SIGNIFICANT

IMPACTS

Traffic and Travel

The Build Alternative contemplates two new passenger stations in King City and 

Soledad. As noted here and in environmental documents adopted/certified by 

 

1

Council on Environmental Quality, 2013
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these cities, buildout of the station areas (which includes the opening of the stations

themselves, increased passenger rail activity, and buildout of surrounding planned 

land uses) would result in increased traffic on local streets. 

In addition, one of the proposed curve realignments could result in a new at-grade 

crossing unless design strategies/solutions can avoid a new crossing. As only 

conceptual curve realignments have been contemplated to date, further design 

refinement has strong potential to avoid creating a new at-grade crossing. 

Land Use and Planning, Communities and 

Neighborhoods, Property and Environmental Justice

Curve realignments and siding extensions that require substantial land 

conversion/acquisition outside of the railroad ROW associated with the Build 

Alternative would commit the land uses and natural resources for an expanded and 

realigned railway in some areas. Future implementation of improvements outside 

the existing right-of-way and in populated areas would have the largest effect on 

existing land uses and communities. Some of the proposed improvements would 

involve displacement of existing residents and businesses, many within an 

environmental justice community, or would convert land uses to be incompatible 

with the general plan. The proposed design and engineering aspects of each 

improvement are conceptual at this time and if carried forward in the future, could

be refined to avoid some or all potential impacts on existing land uses and 

communities. 

Agricultural and Forest Resources

Improvements requiring land outside of the existing railroad ROW, such as curve 

realignments, new sidings, and siding extensions associated with the Build 

Alternative would convert Prime Farmland and other protected types of farmland to 

nonagricultural uses. Prime Farmlands are protected by the state due to the soil 

quality and irrigation status of the land. In CEQA, the conversion of Prime Farmland 

to a non-agricultural use cannot be mitigated below a level of significance. Thus, 

any conversion of Prime Farmland to a non-agricultural use would be considered an 

unavoidable impact. 

If the proposed second mainline is carried forward for construction and additional 

right-of-way is needed, some or all of the additional right-of-way (up to 12 acres in 

in all) could include forest land within the Los Padres National Forest. 
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Biological and Wetland Resources

As further described in Section 3.13, Biological Resources and Wetlands, certain 

proposed curve realignments, new sidings, and siding extensions have the potential 

to entail the use of lands outside the existing railroad right-of-way that are critical 

habitat areas for several protected species (including California red-legged frog and

vernal pool fairy shrimp), habitat of special-status species, sensitive vegetation 

communities, and wetlands. The evaluation in this document is based on a review

of highly conceptual plans for proposed rail improvements. Design refinements may 

be able to avoid some or all of the aforementioned potential effects. 

Hydrology and Water Quality

As further described in Section 3.12, Hydrology and Water Resources, certain 

proposed new sidings and siding extensions, curve realignments, and the second 

mainline have the potential to intersect surface waters, potentially resulting in 

hydrological and/or water quality effects. Design refinements of the conceptual 

plans used in this evaluation could potentially avoid some of all of these 

hydrological and/or water quality impacts. 

Conclusion

Overall, only general statements of potential impacts can be made at this program 

level of review, since there is considerable uncertainty as to which if any elements 

of the Build Alternative will be carried forward for further design, funding, and 

eventual construction and operation. As noted throughout this document, many of 

these elements have only conceptual designs to date. Therefore, the analysis herein 

is based on a review of potential effects to considerably sized “buffer” areas, in only 

a small portion of which any actual physical improvements might be constructed. 

3.17.2 RELATIONSHIP BETWEEN SHORT-TERM USES OF 

THE ENVIRONMENT AND ENHANCEMENT OF LONGTERM PRODUCTIVITY

Implementation of proposed rail improvements may result in property acquisitions, 

conversion of Prime Farmland, and potential disruption of biological and wetland 

resources during construction and operation. Future project-level environmental 

review would consider these factors in more detail if any specific improvements are 

carried forward. While some of the proposed improvements may disrupt the 

existing conditions of the area, short- and long-term benefits would also result and 

should be considered accordingly. 
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The Coast Corridor region is faced with transportation challenges associated with 

anticipated population growth, constrained travel options, aging rail infrastructure, 

safety issues, and a need for increased travel capacity without impacting air quality 

and natural resources. These challenges are likely to continue in the future as 

continued growth in population, employment, and tourism activity is expected to 

generate increased travel demand. 

In the short-term, construction activities would likely increase employment 

opportunities as well as locally purchased materials and services. In the long-term, 

proposed improvements would likely increase the frequency, speed, and reliability 

of passenger rail while fostering greater passenger connectivity to the proposed 

California High-Speed Rail System and enhancing safety with minimal or no 

disruption to existing and proposed freight rail operations. Implementation of the 

Build Alternative would help to create an interconnected, multimodal solution 

allowing for better mobility throughout the Coast Corridor region, providing added 

capacity in response to increased travel demand between Los Angeles and San 

Francisco. 

3.17.3 SIGNIFICANT UNAVOIDABLE ADVERSE EFFECTS 

UNDER CEQA

As discussed, this program-level EIS/EIR evaluates the potential for significant 

effects to occur from any of the proposed Build Alternative improvements. 

Additionally, if any of the proposed improvements are carried forward, this analysis 

offers mitigation strategies that could potentially avoid or minimize impacts to 

resources through project design or other measures. Accordingly, this programlevel EIS/EIR only generally identifies potentially significant unavoidable impacts as 

such consideration would occur during project-level review.

Table S-1, in the Summary of this document, describes the environmental resources 

and potential impacts as a result of the proposed Coast Corridor improvements. 

Depending on which if any proposed improvements are carried forward, potentially 

significant and unavoidable impacts may occur at various locations within the 

corridor. Portions of land immediately adjacent to the Coast Corridor are habitat for 

several protected species; therefore, some of the proposed improvements could

potentially encroach into such land. Additionally, proposed project improvements 

may require property acquisition and conversion of Prime Farmland. Such 

occurrences could potentially result in future conclusions of significant and 

unavoidable impact under CEQA. 
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The No Build Alternative represents the continuation of existing rail operations and 

physical components, and assumes the perpetuation of existing freight and 

passenger service between Salinas and San Luis Obispo. The only physical 

improvement expected under the No Build Alternative would be the installation of 

positive train control (PTC) along the Corridor, which would provide increased safety 

for freight and passenger trains. No specific plans have been identified, but

anticipated PTC related improvements outside train-based equipment would most 

likely take the form of communications apparatus (i.e. antennas, signal upgrades). 

Such improvements are anticipated to be placed within the existing railroad rightof-way and would thus be assumed to have minimal or no effect upon adjacent 

areas to the railroad right-of-way. As a result, significant and unavoidable impacts 

would not likely occur under the No Build Alternative.

3.17.4 CEQA ENVIRONMENTALLY SUPERIOR ALTERNATIVE

CEQA Guidelines §15126.6(e)(2) requires the selection of an environmentally 

superior alternative. Based on the analysis presented in the Program EIS/EIR

(described in Table S-1 in the Summary), the No Build Alternative would be the 

environmentally superior alternative because it would have no potential to result in 

any new construction-related effects, or acquisition/incorporation of any 

agricultural or biologically valuable land into the railroad corridor. However, as 

further described below, the No Build Alternative does not offer potential air quality 

and transportation benefits.

CEQA Guidelines §15126.6(e)(2) also states that where the No Build Alternative is 

considered the environmentally superior alternative, the EIR shall identify another 

environmentally superior alternative. Accordingly, this Program EIS/EIR also 

considered the Build Alternative. While the Build Alternative would potentially 

entail the incorporation of agricultural and/or biologically valuable land into the 

railroad corridor, various components of the Build Alternative would (individually 

and collectively) enhance safety and enable greater reliability for both passenger 

and freight rail traffic. 

Additionally, the Build Alternative would provide increased capacity to assist in 

meeting mobility challenges and travel demand between San Francisco and Los 

Angeles. Under the No Build Alternative, current and projected future system 

congestion would continue to result in reduced reliability, slower travel speeds, 

increased travel times, and deteriorated air quality. The Build Alternative would 

assist in fostering improved rail connectivity to the proposed California High-Speed 

Rail system and would augment the highway system, creating an interconnected, 

multimodal solution, allowing for enhanced mobility throughout the corridor. As 
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demonstrated in this document, the Build Alternative would offer modest but 

measurable improvements in regional air quality insofar as increased rail ridership 

would lead to fewer automotive vehicle miles traveled (VMT) in the corridor. 

Therefore, the Build Alternative has been identified as the environmentally superior 

alternative. 
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